YRF Studios Vs Commissioner of CGST & Central Excise (CESTAT Mumbai)
The appeal challenged the Order-in-Appeal dated 18.08.2025, whereby the Commissioner (Appeals), CGST & Central Excise, Mumbai upheld the denial of CENVAT credit of ₹3,05,114, along with interest and penalty, relating to service tax paid on RCC column strengthening works undertaken during the period October 2014 to June 2017. The proceedings originated from an EA-2000 audit, which treated the services as works contract services excluded from the definition of input service under the CENVAT Credit Rules, 2004.
The appellant, engaged in renting film studios, sound recording studios and providing other taxable services, submitted that the disputed work comprised RCC column strengthening of existing studio buildings, audio wing buildings and installation of decking sheets for refurbishing and strengthening slabs. It contended that these activities constituted repair, renovation and maintenance of existing studio infrastructure and qualified as “input service” under Rule 2(l) of the CENVAT Credit Rules, 2004. The appellant also produced a Chartered Accountant’s certificate dated 26.06.2024 stating that services valued at ₹57,20,892 involving service tax of ₹3,05,114 had been accounted for under “Repairs and Maintenance – Building.” It further argued that the allegation of suppression was unsustainable since all relevant information had been disclosed in statutory records and returns.
